Title
Amargo vs. Court of Appeals
Case
G.R. No. L-31762
Decision Date
Sep 19, 1973
A tenant contested eviction over unpaid rent; courts upheld rulings, citing procedural waivers, indispensable party omission, and presumption of judicial regularity.
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Case Digest (G.R. No. L-31762)

Facts:

1. Background of the Case:

  • The case originated from an unlawful detainer complaint filed by private respondents Manuel de Jesus and Luz Miranda de Jesus against petitioner Julia Asis Amargo on October 10, 1967, in the City Court of Manila.
  • The complaint alleged that petitioner refused to pay the increased monthly rental of P180.00 (from P140.00) for the premises located at 346 Pureza St., Sampaloc, Manila.

2. City Court Decision:

  • After trial, the City Court rendered a judgment on January 15, 1968, ordering petitioner to vacate the premises, pay P380.00 for rents in arrears as of October 1967, and P180.00 as monthly rent starting November 1967 until vacating the premises, plus attorney’s fees and costs.

3. Appeal to the Court of First Instance:

  • Petitioner appealed to the Court of First Instance of Manila. During a pre-trial conference on June 20, 1969, petitioner’s counsel, Atty. Manuel Jimenez, Jr., manifested that after private respondents presented their evidence, he would submit the case for decision.
  • The court delegated the reception of evidence to Commissioner Atty. Romulo J. Lapuz. On June 23, 1969, private respondents presented their evidence, and petitioner’s counsel cross-examined their witnesses. Petitioner’s counsel informed the commissioner that he would file a motion to present evidence for the petitioner.

4. Motion for Reconsideration:

  • On July 12, 1969, petitioner filed a motion for reconsideration, pleading for equity to allow her to present evidence. Private respondents opposed, arguing that petitioner’s counsel had already waived the presentation of evidence.
  • The trial court denied the motion on July 17, 1969, stating that petitioner did not indicate what evidence she intended to present and that the court believed petitioner did not desire to present any evidence.

5. Judgment by the Court of First Instance:

  • On August 30, 1969, the Court of First Instance affirmed the City Court’s judgment. Petitioner’s motion for reconsideration was denied on October 22, 1969.

6. Petition to the Court of Appeals:

  • On October 29, 1969, petitioner filed a petition for review with the Court of Appeals, arguing that the June 20, 1969 Order was not supported by stenographic notes and was therefore invalid.
  • The Court of Appeals dismissed the petition on January 10, 1970, stating that the absence of stenographic notes did not invalidate the order and that petitioner failed to join the plaintiffs in the ejectment case as respondents.

Issue:

  1. Validity of the June 20, 1969 Order:

    • Whether the June 20, 1969 Order, which stated that petitioner’s counsel waived the presentation of evidence, is null and void due to the absence of stenographic notes.
  2. Failure to Join Indispensable Parties:

    • Whether the Court of Appeals correctly dismissed the petition for review because petitioner failed to join the plaintiffs in the ejectment case as respondents.
  3. Presumption of Regularity of Judicial Proceedings:

    • Whether the presumption of regularity of judicial proceedings applies to the June 20, 1969 Order and subsequent proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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